Statement of claim for annulment of full adoption — February 2024

Source and reading notes

This reader contains a complete English translation of the nine-page public redacted PDF. The source is the author's OCR reconstruction of the statement of claim, supplied from a Word document; it is not a verified scan of the original document filed with the court. The filing date, 22 February 2024, is confirmed by the Higher Court's ruling P.98/2024 of 26 February 2024. This OCR copy itself did not establish that date. The date 20 February 2024 on page 2 refers to the power of attorney.

The factual assertions, personal account, legal arguments and requests below are those of the pleading. The text headed “JUDGMENT” on page 9 is the judgment requested by the plaintiff, not a judgment already delivered by a court. Counsel's identity, office details and signature are marked [redacted]. The source's exhibit references are retained as written; they do not establish a new numbered set of archive documents.

Public redacted nine-page source PDF

Childhood with the Vasić family — connected sources

Editorial context: Pages 6–8 give the author's account of beatings, hostility and witnessed violence. The child bears no responsibility for the adults' violence or the breakdown of their marriage.

• The 1979 assessments described a favourable family environment.
• The 1982 divorce records contain statements about nonpayment of maintenance from May 1982 and the axe-and-sow message. The cat beating is recounted here by the plaintiff, not an earlier judicial finding.
• The 1984 consent record contains Milorad's own admission that he had had no contact since August 1983 and had placed the child in foster care to save his new marriage.

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[redacted]

TO THE HIGHER COURT IN NOVI SAD
Sutjeska Street No. 3
21101 Novi Sad

STATEMENT OF CLAIM FOR ANNULMENT OF FULL ADOPTION

Pursuant to Article 358, paragraph 1 of the Family Law (“Official Gazette of the Republic of Serbia”, Nos. 18/2005, 72/2011 — other law, and 6/2015), in conjunction with Article 42 and Article 28 of the Law on Adoption of the Socialist Autonomous Province of Vojvodina (“Official Gazette of SAP Vojvodina”, No. 24/76),

WITH A MOTION FOR THE PRESERVATION OF EVIDENCE

Pursuant to Article 284, paragraph 1 of the Civil Procedure Law (“Official Gazette of the Republic of Serbia”, Nos. 72/2011, 49/2013 — Constitutional Court decision, 74/2013 — Constitutional Court decision, 55/2014, 87/2018, 18/2020 and 10/2023 — other law).

Value of the subject matter of the dispute: incapable of monetary valuation (the dispute concerns the determination of the plaintiff's personal status).

PARTIES TO THE PROCEEDINGS

PLAINTIFF: MILAN PETROVIĆ of Kragujevac, Kraljevačkog bataljona Street No. 110, personal identification number (JMBG): 2806974800030 (hereinafter: the plaintiff), represented by counsel [redacted], an attorney in Novi Sad, [redacted].

DEFENDANT: CENTRE FOR SOCIAL WORK OF THE CITY OF NOVI SAD, of Novi Sad, Zmaj Ognjena Vuka Street Nos. 13–17, registration number 08154902 (hereinafter: the defendant), represented by its legal representative, Director Jelena Zorić.

We submit to the above Court a duly signed and stamped statement of claim in two identical copies, each accompanied by 13 evidentiary attachments, together with the original attorney's power of attorney accompanying the first copy of the statement of claim.

THIS IS THE FIRST COPY OF THE STATEMENT OF CLAIM FOR THE COURT, WITH ATTACHMENTS AND THE ORIGINAL POWER OF ATTORNEY!

[redacted]

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Proper representation of the plaintiff

In this legal matter concerning the annulment of full adoption, the plaintiff will be represented by [redacted], an attorney in Novi Sad, [redacted], under the duly enclosed original power of attorney.

• EVIDENCE: the original power of attorney for counsel dated 20 February 2024, signed by the principal, the plaintiff Milan Petrović.

Establishment of the subject-matter and territorial jurisdiction of the Higher Court in Novi Sad

The right to bring this claim for annulment of full adoption before the Higher Court as the court with subject-matter jurisdiction is prescribed by Article 42 in conjunction with Article 28 of the Law on Adoption of Vojvodina (“Official Gazette of SAP Vojvodina”, No. 24/76), which was in force when the adoption was established. We base the application of that law in this case on Article 358, paragraph 1 of the currently applicable Family Law (“Official Gazette of the Republic of Serbia”, Nos. 18/2005, 72/2011 — other law, and 6/2015), which provides:

“An adoption established before the commencement of the application of this law shall be governed by the regulations that were in force until the date on which the application of this law commenced.”

Article 28 of the Law on Adoption of SAP Vojvodina (“Official Gazette of SAP Vojvodina”, No. 24/76) provides:

“The district court shall decide on the annulment of adoption. The parents, the adopter, the public prosecutor and the adoptee after acquiring legal capacity shall have the right to bring an action for annulment of adoption.”

As district courts no longer exist following the definition of the new court network under the Law on the Organisation of Courts (“Official Gazette of the Republic of Serbia”, Nos. 116/08, 104/09..88/18 and 10/23), and the subject-matter jurisdiction formerly exercised by district courts is now exercised by higher courts, we therefore address this statement of claim to the Higher Court.

We base the territorial jurisdiction of the Higher Court in Novi Sad on the fact that the defendant guardianship authority is located within its territory. That authority issued the decision on the plaintiff's full adoption while committing enormous failures in establishing the statutory conditions for that adoption to take place. Those conditions were not met, rendering the adoption absolutely null and void, as will be explained in the further narrative of the statement of claim. All of this caused irreparable harm to the life of the then minor adoptee, Miletić Milivoj (as the plaintiff was then named), rather than serving his best interests in life.

Facts of the case

Although we do not wish to burden this statement of claim with unnecessary narrative, we must nevertheless emphasise that it is impossible to view this entire case properly without acquainting the Court with certain facts that preceded the adoption proceedings themselves. We will therefore summarise them

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in the following passages so that the Court can gain a comprehensive picture and understand the extent of the illegality committed in this case.

The plaintiff was born on 28 June 1974 in Novi Sad as Miletić Milivoj, from an extramarital relationship. His biological mother, now deceased, was named Miletić Cvita, and his father, also deceased, was Pavle Lakatoš. Although, from a legal standpoint, the father of the minor Miletić Milivoj had not been established because his particulars as the child's father were not entered in the birth register, he was de facto known as the plaintiff's biological father to a wider circle of people, primarily the closest members of his family: his wife Veronika Terezija Lakatoš and the children Roža, Iren and Ištvan. We point out to the Court that we understand that this is not a paternity action, but it is impossible to view the whole matter of the unlawful adoption properly without saying a few words about the facts relating to the plaintiff's origins.

The following primarily supports the assertion that the late Pavle Lakatoš was known to be the plaintiff's biological father. The late Pavle Lakatoš divorced his wife Veronika because of disagreements in their married life. In their divorce proceedings before the District Court in Novi Sad, case No. P.1642/76, the records of the hearings contain statements in several places, made by Pavle Lakatoš himself as a party to the proceedings, by his wife Veronika as the other party, by their daughter Roža, who wished to testify in her parents' divorce proceedings and in whose care the then minor plaintiff was even placed, and by the witness Gabrić Nikola. Those statements say that Pavle Lakatoš had fathered an extramarital child — a son — with the day labourer Cvita, who helped him run his farm and with whom he had meanwhile begun living together.

That fact was plainly disputed by no one. Indeed, the plaintiff's half-sister Roža cared for her little half-brother until Pavle Lakatoš died on 7 November 1978 and the question arose of inheriting his estate, which was not without value.

• EVIDENCE: examination of the plaintiff as a party to the proceedings; inspection of the plaintiff's extract from the birth register of the Municipality of Novi Sad, entry No. 2512 for 1974 (the first registration of birth), issued on 2 June 2023 (attachment No. 1); inspection of the file of the divorce proceedings of Pavle and Vera Lakatoš conducted before the District Court in Novi Sad under case No. P.1642/76.

In the probate proceedings opened after the late Pavle Lakatoš, formerly of Novi Sad, which were conducted before the Municipal Court in Novi Sad under case No. O.196/79, at the hearing on 19 March 1979, attorney Helena Uzelac, counsel for the daughter and heir Roža Lakatoš, stated that, apart from the reported marital children of the deceased, there was another child who was an heir and whom the deceased had had from an extramarital relationship. Admittedly, as she herself stated, it had not been judicially established that the deceased was his father, but he had acknowledged the child as his own on several occasions, kept him and cared for him. Following the death, the minor Milivoj was in the care of the deceased's mother and father. We submit to the Court that attorney Helena Uzelac's foregoing statement about the existence of another heir is crucial to understanding everything that

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follows. Namely, very soon thereafter, more precisely on 3 April 1979, attorney Helena Uzelac ceased to act as counsel for the co-heirs and informed the probate court of this. The co-heirs then engaged new counsel, who succeeded, through an appeal allowed by the second-instance court, in overturning the first-instance court decision declaring the minor Miletić Milivoj a co-heir of Pavle Lakatoš to one quarter of the estate. The grounds of appeal concerned the fact that kinship with the deceased — paternity — had not been established in the manner prescribed by law.

After that, at some point between 19 March 1979 and 21 June 1979, the minor Miletić Milivoj was placed under the authority of the Centre for Social Work of Novi Sad (the then Self-Managing Community of Interest for Social Welfare of Novi Sad, as the legal predecessor to the rights and obligations of the Centre for Social Work of Novi Sad) for the purpose of full adoption.

None of this might in itself have been strange were it not for the fact that it all happened after it was plainly known that, if expert examination established that the minor Milivoj was the deceased's son, he would definitely be entitled to part of the inheritance, regardless of his being a child from an extramarital relationship. To prevent that, there was, unfortunately, a legal route that someone evidently knew very well: the child was to be immediately placed for full adoption. Incidentally, full adoption was at that time more the exception than the rule because the institution of full adoption had only just been introduced into the legal system. This is because Article 38 of the Law on Adoption of SAP Vojvodina (“Official Gazette of SAP Vojvodina”, No. 24/76), which was then in force, states:

“The establishment of paternity and maternity of a fully adopted child is not permitted.”

The matter is so obvious that it could not be more obvious.

• EVIDENCE: examination of the plaintiff as a party to the proceedings; we propose that the Court inspect the probate case file of the Municipal Court in Novi Sad, case No. O.196/79; inspection of the enclosed record of the hearing before the Municipal Court in Novi Sad, case No. O.196/79, dated 19 March 1979 (attachment No. 2); inspection of the enclosed probate decision of the Municipal Court in Novi Sad, case No. O.196/79, dated 23 November 1979 (attachment No. 3).

We now turn to the facts concerning the plaintiff's adoption itself and its nullity. The entire procedure for establishing the adoption proceeded with incredible speed. We cannot determine the period with certainty because the plaintiff did not receive from the defendant the information as to when his adoption proceedings were initiated. What we can conclude with certainty from the available files, however, is that the defendant could certainly not have had the minor Miletić Milivoj under its authority before 19 March 1979. On that date the probate hearing after the late Pavle Lakatoš took place, at which attorney Helena Uzelac stated for the record:

“The minor Milivoj Miletić is currently in the care of his grandmother and grandfather, the deceased's parents.”

The other important date is 21 June 1979, when the plaintiff, then the minor Miletić Milivoj, was placed for full adoption with the adopters Vasić Milorad and Vasić Gospava, a childless married couple from Budisava, both now long deceased. That decision of the defendant was declared in the Record of Full Adoption of the Self-Managing Community of Interest for Social Welfare of Novi Sad, No. 03-507/79 of 21 June 1979. The defendant also issued

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Decision No. 03-507/74 of 21 June 1979, approving the subsequent entry of the parents' particulars in the adoptee's birth register (the plaintiff in these proceedings). The minor Miletić Milivoj became the minor Vasić Milan.

• EVIDENCE: inspection of the enclosed copy of the record of the Municipal Court in Novi Sad, case No. O.196/79, dated 14.03.1979 (attachment No. 2); inspection of the enclosed copy of the Record of Full Adoption of the Self-Managing Community of Interest for Social Welfare of Novi Sad, No. 03-507/70 of 21 June 1979 (attachment No. 4); inspection of the enclosed Decision of the defendant No. 03-507/79 of 21 June 1979, approving the subsequent entry in the birth register (attachment No. 5); inspection of the extract from the birth register for the Novi Sad registration area, entry No. 2463 for 1979, issued on 2 June 2023 — the second registration of the plaintiff's birth (attachment No. 6).

The period within which the defendant supposedly carried out all checks of the adopters' suitability is unprecedented in a matter as extremely sensitive as the adoption of children. It is generally known that adoption proceedings take years and that many prospective adopters even give up because of the complicated and complex procedure. This, of course, resulted in the then minor Miletić Milivoj being placed for adoption with persons who were completely unsuitable to be adopters, because the checks of those persons' suitability were not carried out properly — if any checks were carried out at all — given that the defendant's reports on the adopters' suitability contain a series of platitudes repeated over and over in all similar reports and situations. Anything can be put on paper. In practical terms, it was impossible to assess the adopters' personalities, their relationship with each other, their living circumstances and similar matters adequately, reliably and responsibly within such a short period.

One might again ask why everything was carried out at such speed. The answer is very clear when the following is taken into account: the minor Milivoj was approaching his fifth birthday. He would turn five on 28 June 1979, after which, under the previously mentioned Law on Adoption of SAP Vojvodina, it would no longer have been possible to establish full adoption, because only a child who had not yet reached the age of five could be fully adopted, subject to the fulfilment of the other cumulative conditions. Thus, it was necessary to rush through the procedure before the adoptee turned five. We have already explained that full adoption removes the possibility of establishing paternity and therefore of claiming an inheritance.

Through its employees, using all manner of platitudes and paeans of praise about the adopters, the defendant established completely untrue facts about their suitability in the reports prepared by social worker Vera Radovanović on 12 June 1979, pedagogue Miroslava Gudelj on 18 June 1979, and psychologist Cvetko Ratković on 19 June 1979. To this day, the plaintiff has not been given access to the medical report on the adopters' suitability.

It must also be stressed and underlined that social worker Vera Radovanović was the minor adoptee's “ad hoc guardian”, meaning that she was supposed to protect his rights and interests impartially in the adoption proceedings, while the same person was preparing the findings and opinion on the suitability of

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the adopters, which is absolutely unlawful! On top of all that, she also gave consent for the minor Miletić Milivoj to be adopted, without there being any evidence that the defendant had contacted the plaintiff's biological mother, Cvita Miletić, to obtain her consent to the full adoption.

It is true that Cvita Miletić was not with the plaintiff, but her whereabouts were not unknown: she was living the whole time at Veselina Masleše Street No. 42 in Novi Sad. Pursuant to Article 30, paragraph 1 of the Law on Adoption of SAP Vojvodina, the defendant was obliged to search for her for six months; only if that period of searching for the biological mother elapsed unsuccessfully could the child be placed for full adoption. Had an attempt been made to contact the plaintiff's mother, she would have been found at the residential address stated above.

That did not happen, however, and consent to the adoption was given by social worker Vera Radovanović, who at the same time assessed the adopters and their suitability (!), while the minor adoptee was left without his right to a guardian who would represent his interests impartially in such a sensitive matter of life — perhaps the most sensitive matter for a human being.

• EVIDENCE: examination of the plaintiff as a party to the proceedings; inspection of social worker Vera Radovanović's report of 12 June 1979 (attachment No. 7); inspection of pedagogue Miroslava Gudelj's report of 18 June 1979 (attachment No. 8); inspection of psychologist Cvetko Ratković's report of 19 June 1979 (attachment No. 9).

A series of facts demonstrates the untruth of the assertions that the late Milorad and Gospava Vasić were suitable to be the plaintiff's adopters and to raise him to become a useful member of the socialist society of that time, as required by Article 11, paragraph 1, item c) of the Law on Adoption of SAP Vojvodina, failing which the adoption is null and void.

The plaintiff's late adopters, Milorad and Gospava Vasić, were a completely dysfunctional married couple with serious, long-standing problems in their marital relationship, dating back many years before they adopted the plaintiff. Milorad was a very disagreeable and difficult man and frequently practised marital infidelity. He was nine years younger than his wife and in the prime of his life, which demanded satisfaction of a sexual drive that was not pronounced in his wife; this, among other things, caused problems in their marriage.

Gospava was very psychologically unstable and suggestible. She even visited a dubious woman who told her fortune by reading tarot cards and beans, taking the plaintiff with her, which at the time was interesting to the child and certainly left an impression. In addition, without any intention of insulting anyone, Gospava was illiterate, as was even recorded in the report of psychologist Cvetko Ratković, an employee of the defendant, dated 19 June 1979. She even joined the Jehovah's Witnesses, who are known to refuse blood transfusions for their children, which could also have endangered the minor adoptee's safety and health.

As is known to the witness Vinka Ignjatić of Budisava, who was their neighbour and knew the adopters well, Gospava complained to her that Milorad mistreated her and that every little thing bothered him. She therefore began taking various sedatives. She also complained to the witness that he was pressuring her to adopt a child and save their marriage, which was terrible. Gospava did not want that, but yielded to the persuasion of

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her husband. After the child arrived in that environment, unstable for normal growth and development, things deteriorated further. Conflicts between the adopters became increasingly frequent. Gospava and Milorad had no love for the child at all. The adoptee and his friends, who came to his home to play, even witnessed physical fights between the spouses, which had also occurred before the child came into the family.

The plaintiff clearly remembers certain fragments of that period of his life, which, as he himself says, was hellish. Milorad beat him, while Gospava also frequently displayed hostility towards him. Of course, it was only a question of when the adopters' marriage would collapse, which happened very soon, in 1982, when divorce proceedings were initiated.

Even before the divorce proceedings were initiated, Milorad left the marital household and the child. According to Gospava herself in the divorce proceedings conducted before the Higher Court in Novi Sad under case No. P.1106/82, they were divorcing, among other reasons, because of the adopted child, as they could not agree on his upbringing and care.

Among other things, in those divorce proceedings, Gospava stated for the record that Milorad had advised her to “take an axe and kill the sow that she did not know what to do with”. Gospava displayed sadism towards animals: in front of the then minor adoptee she brutally beat a cat that had entered their house. We ask ourselves how the defendant adequately checked the adopters' suitability in the face of such facts.

But that is not the end. Not long after the adopters' divorce, Gospava died in April 1983. Instead of father Milorad, who had supposedly wanted a child so much, giving him at least a little love, he placed him with a foster family, maintaining no further contact with him and making no contribution to his maintenance, although he was obliged to do so. Already in September 1984, he placed his adopted son Milan Vasić for incomplete adoption with the adopters Petrović Periša and Gorgina of Kragujevac. Thus, the then minor Milan Vasić became Milan Petrović, the name he still bears today.

Although Milorad continued to have obligations towards the child, because the child had been placed for incomplete adoption, which does not terminate the duties of parents (in this case, adoptive parents), he did not care at all, and all contact with the plaintiff was broken off.

• EVIDENCE: examination of the plaintiff as a party to the proceedings; examination of the witness Ignjatić Vinka of Budisava, Petefi Šandora Street No. 168; examination of the witness Dragan Ignjatić of Budisava, Petefi Šandora Street No. 168; inspection of the file of the divorce proceedings of the adopters Milorad and Gospava Vasić before the Higher Court in Novi Sad, case No. P.1106/82; inspection of the enclosed hearing record of the Higher Court in Novi Sad in divorce case No. P.1106/82 of 20 September 1982 (attachment No. 10); inspection of the enclosed Record of Incomplete Adoption of the minor Vasić Milan by Periša and Gorgina Petrović, Centre for Social Work of Novi Sad, No. UP.02-987/84 of 26 September 1984, with Vasić Milorad's statement of consent to the adoption (attachment No. 11); that

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the Court officially request the medical record with the medical history of the late Gospava Vasić from the Health Centre in Budisava.

(We reserve the right to propose additional evidence.)

Were these truly suitable adopters, who should have been like a biological father and mother to the child, given him all their love and tenderness and raised him in a healthy spirit so that the child would have a chance of a successful life? We must view the entire situation from the perspective of socialist society and its values, because the Law on Adoption requires this. The highest aim of socialism, at least ideologically, was “the personal happiness of the human being”.

Instead of fulfilling its task and finding and securing adopters who would give the child the best conditions for proper growth, development and happiness, in which the child would develop so as one day to become a “useful member of socialist society”, the defendant placed him in the worst possible living conditions. He escaped those conditions solely and exclusively because of the circumstances of life that took him out of that “caring environment”: adopter Milorad left others to care for him, and adopter Gospava departed this world.

None of this would have happened if proper checks had been made as to what kind of people the adopters were. The child's life would not have been made a literal hell, the consequences of which can never be remedied. The plaintiff never experienced these imposed adopters as real adopters or parents and therefore never claimed anything after their deaths, although he is their heir by law.

Legal framework

Article 41, in conjunction with Article 11 of the Law on Adoption of SAP Vojvodina (“Official Gazette of SAP Vojvodina”, No. 24/76), prescribes the conditions for nullity of adoption — not cumulative, but alternative. Thus, it provides that:

“A person who may be considered unlikely to raise the adoptee to become a useful member of socialist society is not permitted to adopt.”

That was definitely the case here, not just for one adopter but for both. This will also be established in the evidentiary proceedings and constitutes sufficient grounds for annulling this full adoption.

The aforementioned article also states:

“A person suffering from an illness that may endanger the adoptee's health and life is not permitted to adopt.”

We have well-founded suspicions that Gospava Vasić was not an entirely healthy woman, and we have proposed that the Court officially check that circumstance with the competent medical institution.

Likewise, Article [number absent in the source] of the Law on Adoption of SAP Vojvodina (“Official Gazette of SAP Vojvodina”, No. 24/76) provides:

“Only a child who has not yet reached the age of five, whose parents are not alive or are unknown, or have abandoned the child and whose whereabouts have not been established even after the expiry of a period of six months from the abandonment of the child, may be fully adopted.”

The adoptee's mother was not unknown, her whereabouts were not unknown, and she was alive when the adoption was established. The plaintiff therefore does not understand why

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her consent to his adoption was not sought, even though her residential address was known. There are therefore several statutory grounds on which this adoption is null and void, and the existence of only one of them is certainly sufficient for the adoption to be annulled.

Prayer for relief

In view of all the relevant facts set out above and the stated legal framework, we consider that the conditions for annulment of the plaintiff's full adoption have been met. We therefore request that, after an oral hearing and the taking of all evidence, the above Court deliver the following:

JUDGMENT — PROPOSED IN THE STATEMENT OF CLAIM

The plaintiff's claim IS UPHELD as well-founded.

The full adoption established and declared by the decision of the Self-Managing Community of Interest for Social Welfare of Novi Sad, No. UP.03-507/79 of 21 June 1979 in Novi Sad, IS ANNULLED as absolutely null and void. By that decision, Vasić Milorad, born on 15 February 1941 in Osječani, Municipality of Doboj, and Vasić Gospava, born on 21 August 1932 in D. Klakar, Municipality of Doboj, both residing in Budisava, Petefi Šandora Street No. 52, adopted the minor Miletić Milivoj, and the adopted minor Miletić Milivoje received the new name Vasić Milan.

The defendant IS ORDERED, immediately upon receiving this judgment, to issue a decision annulling the Decision of the Self-Managing Community of Interest for Social Welfare of Novi Sad, No. UP.03-507/79 of 21 June 1979, which approved the subsequent entry in the birth register of the particulars of the adopters Vasić Milorad and Vasić Gospava of Budisava as the parents of the fully adopted child, the plaintiff in these proceedings, so that annulment of that decision shall restore the effect of the first registration of the birth of the fully adopted child, the plaintiff in these proceedings.

The defendant IS ORDERED to reimburse the plaintiff in full for the costs of these civil proceedings, in the amount in which they are incurred, together with statutory default interest from the date of enforceability until payment, all within 15 days from the date on which the judgment becomes final, failing which enforcement shall follow.

Editorial note on source references

The translation retains the source's references 03-507/74 and 03-507/70, and its date 14.03.1979 on PDF page 5. Elsewhere in this pleading and in the related archived adoption records, the adoption reference is 03-507/79; the archived probate hearing record is dated 19 March 1979. These differences have not been silently corrected. PDF page 8 leaves the article number missing in the passage on the child's age and parental status; the translation marks that omission rather than supplying a number. The proposed judgment on page 9 also retains the source's form Milivoje in one reference to the child.

The pleading names the pedagogue Miroslava Gudelj; the archived report of 18 June 1979 is signed Milosava Gudelj. The “after that” sequence on page 4 is retained as written: the adoption dated 21 June 1979 predates the first-instance probate decision dated 23 November 1979 cited in the pleading. That narrative wording is not used to change the chronology of the archived events.